Stephanie D. Willis

Stephanie Willis is a member of the firm's Health Care Group in Crowell & Moring's Washington, D.C. office. She counsels health care clients in matters involving regulatory issues, including fraud and abuse compliance, participation in new health care reform initiatives under the Affordable Care Act (ACA), as well as Certificate of Need (CON) and licensure matters. She has also advised clients on compliance with laws and regulations governing health IT initiatives and health care privacy and security, including the Health Insurance Portability & Accountability Act (HIPAA).

The following list illustrates the range of Stephanie’s health care law experience:

Fraud and Abuse Compliance Matters:

Coordinating a large university health system’s internal investigation of its financial arrangements with physicians for compliance with the Physician-Self Referral Law (Stark Law) and subsequent reporting under the Centers for Medicare & Medicaid Services (CMS) Self-Referral Disclosure Protocol (SRDP).

Providing critical analysis and compliance advice to a U.S. subsidiary of an international pharmaceutical company regarding its potential liability and reporting obligations under the Physician Payments Sunshine Act enacted under the ACA.

Managing the internal investigation and drafting of key notifications to patients related to unauthorized disclosures of data by a Medicaid managed care organization.

Advising a non-profit Federally Qualified Health Center (FQHC) on the review and implementation of its privacy and security policies and procedures under HIPAA and analogous state laws.

Certificate of Need/Licensure Matters:

Drafting and submitting CON applications and related filings for retail clinic, renal dialysis facility, and an acute care hospital, including a successful application for the largest hospital construction project in District of Columbia’s history.

Providing representation, including submission of interested party comments challenging CON applications filed in the District of Columbia and Maryland.

Providing regulatory counseling and advice to health care entities participating in other CMS-administered programs including the Comprehensive Care for Joint Replacement Initiative, Oncology Care Model, and Next Generation ACO Model.

In addition, Stephanie previously served as a contributing author for the District of Columbia Practice Manual’s chapter on Health Maintenance Organizations, and is currently one of the authors of the chapter on Managed Care Fraud and Abuse in the American Bar Association’s Health Care Fraud and Abuse: Practical Perspectives treatise. She also frequently writes blog posts and articles on emerging health care regulatory developments and is an active part of the firm’s multi-practice initiatives that focus on issues of relevance to multiple industries, such as Digital Health/Health IT, the Internet of Things (IoT), and Privacy and Cybersecurity.

Affiliations

Admitted to practice: District of Columbia, Massachusetts (inactive)

Leadership Positions

American Health Lawyers Association

Young Professionals Council Vice Chair (2014-2015)

Young Professionals Council Delegate to the Board of Directors (2015-2016)

Fundamentals in Health Law Conference Planning Committee (2016)

American Bar Association, Health Law Section

Web & Technology Committee (2014-current)

National Association of Health Services Executives-Washington Metropolitan Area Chapter